CBI/CIP Countries on Cusp of Passing New Law for Establishment of Regional Regulator
After months of extensive consultations, the countries in the Eastern Caribbean that offer Citizenship By Investment Programmes (CBI/CIP) are on the cusp of enacting legislation to establish a regional regulator. This new law will be enacted in September 2025 by all five member countries.
The enactment of this law will culminate an intense and historic period of engagement and cooperation on these Programmes, which are so vital to the fiscal, financial stability and resilience of these member countries.
Some engagement milestones include:
1. Inaugural US-Caribbean Roundtable that resulted in the signing of an agreement on six principles between the USA and the five CBI/CIP countries in February 2023 in St. Kitts and Nevis.
2. Roundtable with the USA and the five CBI/CIP countries in October 2023 (USA).
3. The signing of a Memorandum of Agreement among the CBI/CIP Heads in March 2024 and June 2024.
4. Meeting with EU officials in January 2024 (Dominica).
5. The introduction of a minimum price of US$200,000 for all CBI/CIP Programmes from July 2024.
6. Roundtable with the USA, UK and EU in August 2024 (Grenada).
7. Roundtable with the UK, USA and EU in January 2025 (London, UK).
8. Broad-based and extensive stakeholder consultations on the establishment of a regional CBI/CIP regulator between March and July 2025.
9. Engagement with the USA and UK in April 2025 (Antigua and Barbuda).
10. Feedback on the draft legislation from the USA and the UK in July 2025.
Throughout these engagements and dialogue, all partners have recognised that CBI/CIP Programmes provide a legitimate service and have assisted in the survival of our member countries by providing revenues that are invaluable for funding major infrastructural and development projects, and for building resilience.
The economic importance of these Programmes cannot be overstated, particularly considering the existential threat to our vulnerable small island states – emanating from the climate emergency – and the onslaught of recent adverse external shocks such as the pandemic and the ongoing war in Ukraine.
It has been accepted that dismantling these Programmes would severely compromise the prospects and prosperity of these countries, triggering a plethora of negative social consequences.
The CBI/CIP countries have strongly affirmed their commitment to a collective fight to safeguard their respective financial systems against threats from illicit finance flows from money laundering, fraud, terrorist financing and proliferation financing.
Some of the key provisions of the enabling legislation for the CBI/CIP regulator include:
1. Establishment and funding of the regional CBI/CIP regulator. The key objectives of the regulator are to help enhance the transparency, security and sustainability of these vital Programmes. The regulator will issue binding standards on all CBI/CIP Units (CIUs) and all licensees involved with these Programmes.
2. Strong enforcement mechanisms for compliance. The regulator will be empowered in law to hold CIUs and licensees to account and will publish annual reports on compliance.
3. Collection of biometrics for all new applicants. Biometrics will be collected at the time of the interview, which is part of the application process. This provision is intended to enhance the security of these Programmes by further strengthening the vetting process of all applications.
4. Residency requirement for all approved applicants. This provision will strengthen the link between new citizens and their countries of citizenship and will allow for verification of biometrics collected during the application process. Moreover, it will generate a direct boost to tourism in our countries and will create other economic opportunities for our member countries.
5. Financial support for CARICOM IMPACS/JRCC. This will strengthen the Joint Regional Communications Centre’s (JRCC’s) capacity (personnel and technology) to continue to provide vetting of all applicants via a central portal. The JRCC plays a central role in the vetting process for all applicants under the CBI/CPI Programmes. No applicant is approved without clearance from the JRCC.
The work leading to the crafting of this new law has been led by an Interim Regulatory Commission (IRC) with membership from all five CBI/CIP countries, the Organisation of Eastern Caribbean States (OECS) Commission, CARICOM IMPACS/JRCC and the Eastern Caribbean Central Bank (ECCB). Ms. Lydia Elliott serves as the Legal Drafting Consultant. The work of the IRC has been overseen by the five Heads of Government of Antigua and Barbuda, Commonwealth of Dominica, Grenada, Saint Christopher (St. Kitts) and Nevis and Saint Lucia.
The CBI/CIP countries wish to express gratitude to international partners, especially the United States of America and the United Kingdom, for their helpful feedback on the draft legislation, which was shared with them in early July 2025.
The CBI/CIP countries also express appreciation for the very useful comments received from other stakeholders, including Attorneys General and Chief Parliamentary Counsel, CIUs, industry participants (local and external) and other local stakeholders.
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